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Program Description

This program details the process required to obtain and complete a hot work permit to perform hot work (welding, burning, and cutting) activities. These procedures have been established to prevent accidental fires, loss of life, injury from exposure to sparks, heat, or flames, and/or property loss. The purpose of this program is to provide guidelines for open flame activities and to establish a permit process for these activities. The scope of this program covers all hot work activities performed by [Company Name] employees.

Definitions

Brazing and soldering – Uses molten metal to join two pieces of metal.

Combustible materials – Solid materials capable of igniting and burning.

Confined space – A space with all the following characteristics:

  1. Large enough and so configured that a person can bodily enter and perform assigned work
  2. Limited or restricted means for entry or exit
  3. Not designed for continuous employee occupancy

Confined spaces can be classified into two categories:

  • Low-hazard non-permit required confined spaces
  • High-hazard permit-required confined spaces

Low-hazard confined spaces are confined spaces that do not contain or have the potential to contain any atmospheric or other hazards capable of causing death or serious physical harm. A low-hazard confined space may become a high-hazard confined space if there are hazardous materials brought into the space or if hazardous activities (welding, brazing, or cutting) are conducted in the space, which may alter the atmosphere of the space.

Permit-required confined spaces are those spaces that (OSHA definition):

  • Contains or has the potential to contain a hazardous atmosphere

  • Contains a material with the potential to engulf someone who enters the space

  • Has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section

  • Contains any other recognized serious safety or health hazards 

Cutting – Any process, including grinding, that produces sparks capable of igniting combustible or flammable materials and transmits heat to the work material.

Fire watch for welding activities – At least one individual dedicated solely to the look out and control stray fires.

Flammable compressed gas – Flammable compressed gases have dangers besides high pressure. These gases can easily catch fire and burn rapidly. These typically include acetylene, hydrogen, natural gas, propane, methylacetylene, and propadiene (MAPP gas).

Flammable materials – Solid or liquid materials capable of igniting at a low temperature and continuing to burn.

Grinding – The use of an abrasive wheel or material to cut, polish, or smooth a substrate.

Hot work – Operations such as welding, cutting, burning, brazing, soldering, heating, or grinding, where spark, slag, or intense heat are capable of igniting combustible materials or flammable atmospheres.

Hot work permit – An employer's written authorization to perform operations capable of providing a source of ignition.

Shielding – Non-combustible welding drapes used in hot work areas. Visible signs should be displayed on shielding while hot work is being performed.

Smoldering – A slow combustion of material without visible light and generally evidenced by smoke and an increase in temperature.

Soldering – Uses metals with a melting point below 800 degrees and is commonly used to join electrical, electronic, and other small metal parts.

Torch operations – The use of any type of torch to cut, braze, solder, or weld.

Welding – Most common way of permanently joining metal parts. In this process, heat is applied to metal pieces, melting and fusing them to form a permanent bond. The following lists the most commonly practiced forms of welding:

  • Oxygen-fuel gas welding – The act of joining metal by generating extremely high heat during combustion.
  • Resistance welding –The act of joining or cutting metals by generating heat through resistance created by the flow of an electric current.
  • Arc welding –The act of joining or cutting metals by generating heat from an electric arc that extends between the welding electrode and the electrode placed on the equipment being welded.
  • Tungsten inert gas (TIG), also known as gas tungsten arc welding is often used with stainless steel or aluminum. TIG uses welding rods, where the welder holds the welding rod in one hand and an electric torch in the other hand. The torch is used to simultaneously melt the rod and the work piece together. Similar to MIG welding. Inert gas is used to shield the point of welding.
  • Metal inert gas (MIG), also known as gas metal arc welding uses a spool of continuously fed wire, which is a consumable electrode. Electricity is flowed into the electrode causing it to melt where it arcs resulting in melted, flowable metal. Inert gas is used to shield the point of welding. Similar to TIG welding.

Responsibilities and Specific Program Components

Employees

  • Follow all warning signs, barricades, and barriers posted around hot work activities
  • Immediately report any signs of smoldering flames

Design and Construction Services

  • For new construction activities and renovation projects, assist EH&S in the intent of this program
  • Complete required hot work permit request form when necessary
  • Ensure that all contractors (both general and sub) post permits for the duration of the hot work
  • Ensure that fire protection and extinguishing equipment is available at the site before starting the job
  • Ensure that the contractor is performing the required minimum fire watch
  • Maintain documentation of current and cancelled permits

Fire Watch for Welding Activities

  • The fire watch may only be performed by an individual who is not performing any other duties that would take attention away from the area where the hot work is performed
  • Be aware of the inherent hazards involved in hot work
  • Ensure that safe conditions are maintained during the hot work
  • Ensure that appropriate fire extinguishers are readily available at the job site
  • Know how to report a fire or other emergency situation
  • Use appropriate personal protective equipment (PPE)
  • Be trained in fire safety procedures and the use of fire extinguishing equipment
  • Have access to at least a 10-pound ABC fire extinguisher at all times
  • Must remain in a location that allows immediate communication with the individual(s) performing hot work
  • Be familiar with the surrounding facilities to sound an alarm in the event of a fire
  • Watch for fires in all exposed areas for a minimum of 30 minutes (including lunch and break times), sound the alarm if necessary, and try to extinguish fires only when obviously within the capability of the equipment available
  • Ensure that no condition arises, or action is taken, that will lead to a hazardous situation in the hot work area
  • Must remain in the work area after work is completed to ensure the risk of fire from hot work has passed (minimum of 30 minutes).

Safety Department

  • Review and approve all hot work permits for all other activities, excluding construction activities
  • Contact lead or supervisor to obtain more specific information about hot work activities, or visit the work site, as deemed necessary
  • Stop hot work activities that do not have a proper permit on display
  • Audit hot work permits and procedures on a periodic basis
  • Coordinate and/or conduct welding, burning, and cutting training
  • Serve as a technical resource for fire prevention issues

Program Components

All employees intending to perform hot work activities must complete a hot work permit request form.

How to Get and Complete a Hot Work Permit

To expedite the hot work permit process, permit requests should be submitted at least 48 hours prior to the commencement of hot work.

  1. Post the signed and approved hot work permit in the vicinity of where the hot work will be performed and for the duration of the hot work activity. Permits must be posted at the job site in an accessible and conspicuous location. Job site trailers are an acceptable location.
  2. Once the hot work has been stopped, finished, or completed, perform a fire watch for at least 30 minutes after hot work activity has been completed.
  3. After the work under the permit is completed and the fire watch has been completed, obtain a copy of the permit for record keeping purposes.

A hot work permit will NOT be issued if the following conditions exist:

  • Sprinkler protection is impaired.
  • Sprinklers, hose streams, and extinguishers are not in service and inoperable.
  • Appropriate fire extinguisher is not immediately available for use.
  • Combustible or flammable materials are within 35 feet and cannot be moved or protected from ignition sparks.
  • An explosive atmosphere exists. Use air-monitoring equipment to determine safe levels of combustible gases and vapors.
  • All wall and floor openings are open and not covered.
  • Work is not covered underneath by a fire-resistive tarpaulin or similar material.
  • Cutting or welding on pipes or other metals conducts enough heat to ignite combustible materials located nearby.
  • Fire Watch personnel performing other duties.

Compressed gas cylinders (CGCs) - Compressed gas cylinders have inherent dangers aside from using them in hot work activities. The handling and storage of compressed gas cylinders must be undertaken with great care. A primary danger of oxygen-fuel gas welding operations stems from welding with CGCs containing oxygen and acetylene. If CGCs are damaged, gas can escape with tremendous force and the vessel itself can explode, causing severe injuries. A condition called "rocketing" can occur when a CGC ruptures and is propelled with such force that it can penetrate a concrete wall.

Handling – The following guidelines should be followed when working with CGCs:

  • Cylinders should be secured in the upright position to prevent tipping.
  • Regulators must be compatible with the cylinder and its content. Many regulators are similar in design and construction, so it is necessary to check the regulator's model number and compare it with the cylinder's requirements to ensure compatibility.
  • Cylinder carts equipped with cylinder restraints such as a chain or strap should be used for transporting and while using CGCs. Never drop cylinders or let items fall on them.
  • Do not accept delivery of acetylene CGCs that arrive in the horizontal position. Transporting cylinders in this manner makes them much more susceptible to explosion.
  • CGCs should be inspected before using to check for leaking, corrosion, cracking, burn marks, contaminated valves, worn hoses and faulty connectors, or broken gauges. If any defective condition is discovered, the CGC should not be used.
  • Never open valves until regulators are drained of gas and pressure adjusting devices are released. When opening CGCs, point outlets away from people and sources of ignition and open valves slowly. On valves without handle wheels, use only supplier recommended wrenches. On valves with handle wheels, never use wrenches. Never use a hammer to turn a handle wheel open or closed.
  • When cylinders are empty, close and return them. Empty CGCs must be marked "MT" or "Empty".
  • All cylinders should have a flash-back arrester located between the hose and the valve.

Storage – The following guidelines should be followed when storing CGCs:

  • Oxygen and fuel gas cylinders must be stored separately with protective valves in place.
  • Oxygen and acetylene must be stored at least 20 feet apart, and separated by a non-combustible wall at least 5 feet in height.
  • Regulators must be compatible with the CGC and designed for the appropriate cylinder.
  • Check the manufacturer's model number and compare it with the gas supplier's requirements and with the gas cylinder.
  • Cylinder carts must be used to transport cylinders from location to location.
  • Cylinders must be secured from tipping and secured in an upright position while in use. The cylinder must be braced from tipping over by placing a strap or chain around the top third of the cylinder.
  • Empty or unused gas cylinders must be promptly returned to the supplier.
  • Gas cylinders and welding equipment must be left outside the work space where the work was performed. Examples of such locations include boilers, tanks, or pressure vessels.
  • Heavy portable equipment mounted on wheels must be securely blocked to prevent movement.
  • Protective valve caps should be in place on the CGC when it is placed into storage. This will reduce the likelihood that a blow to the valve will result in leakage.
  • When stored, CGCs should be arranged in such a way that old stock will be used before new stock.
  • All cylinders will be positively closed at the valve when leaving them for storage for extended periods (overnight). Do not rely on the torch control valve.

Confined Spaces – When performing hot work in confined spaces, employees must comply with the confined space entry program. In addition, employees must adhere to the following guidelines:

  • Keep all gas cylinders and welding machines outside of confined spaces.
  • Positively isolate the gas supply outside the confined space when torches are not in use for a substantial period of time (such as during lunch). When practical, employees should remove torches and hoses from confined spaces.
  • De-energize electrode holders by electronically disconnecting the power supply when arc welding is to be suspended for an appreciable amount of time or when the welder must leave the job.
  • Use insulating mats or similar insulating equipment to protect welders using alternating current equipment over 50 volts from electrical contact with conductive materials.
  • Ensure that available ventilation in the confined space meets the ventilation requirements.
  • Avoid bringing hot work into non-permit required confined spaces. If hot work hazards are introduced into these spaces, the status of the space will change and a permit will be required to enter these spaces.

Engineering Controls – Ventilation should be adequate, depending on volume and configuration of space, number and type of operations that are generating contaminants, natural air flow rate where operations are taking place, location of the welding breathing zone, and whether ventilation can be obtained mechanically or naturally.

Ventilation and Atmospheric Testing – Ventilation techniques for welding operations vary depending on size and type. For basic operations, fans will provide sufficient  ventilation. However, ventilation should never be relied on as the only method of protecting employees when it is suspected that air contaminants are present. Where ventilation is poor, respirator use should be evaluated before hot work activities commence. Ventilation of the space where hot work is going to occur should be evaluated based on the guidelines provided below:

    • Hot work should not be conducted in the presence of explosive mixtures of flammable gases, vapors, liquids, or dusts or where explosive mixtures could develop inside improperly prepared tanks or equipment.
    • Atmospheric testing and monitoring for combustible gases and vapors must always be conducted inside a confined space before work commences and at regular and predetermined intervals thereafter. Continuous real-time monitoring may be required if indicated by atmospheric conditions or if highly toxic contaminants are present and have the potential to reach IDLH levels. Contact EH&S for additional assistance.
    • While working in poorly ventilated spaces, exposure to air contaminants generated by welding or cutting must be controlled by ventilation, respiratory protection, or by a combination of the two.

Fire Watch – A fire watch is required whenever welding or cutting is performed in locations where an incipient stage fire might develop, or whenever any of the following conditions exist:

  • Appreciable combustible materials are closer than 35 feet to the point of operation.
  • Appreciable combustibles are present which can be ignited by sparks.
  • Wall or floor openings within a 35-foot radius exposure to combustible materials in adjacent areas including concealed spaces in walls or floors.
  • Combustible materials are adjacent to the opposite side of metal partitions, walls, ceilings, or roofs and are likely to be ignited by conduction or radiation.

A fire watch must be maintained for a minimum of 30 minutes after completion of hot work to detect and extinguish smoldering fires. Suitable fire extinguishing equipment must be maintained and be ready for use while welding, cutting, and burning activities are performed and during the fire watch.

Warning signs, barricades, and barriers – In order to control traffic, barriers and proper signs must be posted to ensure traffic is prevented from exposure to hot work areas. Shields should be used to prevent exposure to sparks and flashes. A clear path to an exit of at least 44 inches must be maintained at all times. Whenever possible, vehicular traffic should be kept out of hot work areas while work is in progress.

Isolation of fire detection systems – Fire detection equipment must be protected from false activation and damage. If hot work impacts the fire detection system, the building and maintenance personnel must be notified  for proper instructions to deactivate, disable, or take off line any devices in the impacted area. Work must not proceed until the building and maintenance personnel  confirms the deactivation of the impacted fire alarm devices. Minimal impairment of the fire detection systems must be maintained at all times. Project manager (PM), inspectors of record (IOR), tradesmen, and contractors must ensure fire detection systems are isolated where hot work is being performed, as appropriate.

Personal protective equipment (PPE) – The following PPE must be used to protect the employee from physical hazards while performing hot work:

  • Goggles and/or safety glasses must be worn to protect the eyes
  • Welding helmets must be worn to protect the face and to protect users from arc rays, welding sparks, and splatters
  • Protective clothing must be worn to cover all body parts and to protect against ultraviolet and infrared flash burns
  • Flame-resistant gloves must be worn to protect the hands during hot work activities

Training Requirements and Competency Assessment

All employees intending to perform hot work activities must attend the following training:

  • Initial welding safety (hot work) training
  • Refresher training (as appropriate)

Employees are also required to attend training when a new process or equipment has been obtained, when an unsafe act has been observed, or when the supervisor feels that retraining is necessary.

Welding safety training includes the following topics:

  • Proper equipment operation
  • Handling and storage of welding materials
  • Compressed gas cylinder safety
  • Physical and chemical hazards
  • Hazard control
  • PPE selection and use
  • Fire precautions
  • Fire watch
  • Hot work procedures, including how to obtain the written hot work permit.

Additional information may be found in CFR 1910 subpart J, CFR 1910 subpart Q, Compressed Gas Association, National Fire Protection Agency (NFPA 1).